The principle from In re Universal Distributing Co Ltd — that costs of realisation of secured assets must be borne by the fund before distribution to secured creditors — applies equally to registered mortgages over Torrens system land, and the indefeasibility principle does not prevent this. A liquidator must first seek remuneration from non-trust company assets before resorting to trust property. Where costs cannot be attributed to individual trusts, they should be apportioned pro rata.
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